We recommend delaying the reporting of the CD until 2023, when it matures, as permitted under the Illinois Revised Uniform Unclaimed Property Act (Illinois RUUPA).

The Illinois RUUPA states that automatically renewable time deposits do not need to be reported and paid to the Treasurer when doing so would cause the owner to pay a penalty or forfeit interest (such as paying an early-withdrawal penalty on a renewable CD). Instead, you may delay reporting and paying the CD to the Treasurer until a penalty or forfeiture would no longer result from delivery of the property to the State Treasurer.

When the CD matures in 2023, you would report and deliver the property on your next reporting date, November 1, 2023, and indicate in your report that “the property is being reported on an extended date pursuant to” Section 15-603(b) of the Illinois RUUPA.

For resources related to our guidance, please see:

• Illinois RUUPA, 765 ILCS 1026/15-603(b) (“If property in a report under Section 15-401 is an automatically renewable time deposit and the holder determines that a penalty or forfeiture in the payment of interest would result from paying the deposit to the administrator at the time of the report, the date for reporting and delivering the property to the administrator is extended until a penalty or forfeiture no longer would result from delivery of the property to the administrator. The holder shall report and deliver the property on the next regular date prescribed for reporting by the holder under this Act after this extended date, and the holder shall indicate in its report to the administrator that the property is being reported on an extended date pursuant to this subsection (b).”)